2012-11-28_PERMIT FILE - C1980007A

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West Elk Mine The primary means of marking the perimeter of the West Elk Mine permit area, including the affected area of the mined and planned underground mine workings (although not required by regulation), will be with GPS technology. This "virtual" perimeter marker system will consist of a computer file of standard GPS transfer format or other format acceptable to the Division, accurately depicting the permit area boundary. This data file will be provided to the Division for entry into mobile GPS units for use in the field if needed to determine the location of the permit area boundary and /or confirm that MCC's existing land disturbing activities or facilities are within. the approved boundary. This GPS perimeter marker file will be updated and maintained by MCC until final bond release. Some advantages of this virtual perimeter marker system are that it is accurate, does not require physical resources, has no visual impact, is easily maintained and updated, cannot be altered without the Division's knowledge, does not increase the reclamation liability and it does not complicate final bond release with marker removal issues. The use of the virtual perimeter marker system is also consistent with direction from the US Forest Service, Paonia Ranger District restricting the use of signs and markers on the Gunnison National Forest. When MCC's proposed land disturbing activities for the mine's long -term surface operations or facilities approach the permit area boundary, physical markers have been and will be utilized, if need be, to alert equipment operators of the limits of the approved activities within the permit area. Physical markers include MCC's permit and affected area signs or white PVC pipes (about four feet in length, placed over steel posts, rebar or similar materials). Markers have been and will be placed (prior to land disturbing activities) along the collective outside perimeter of the main mine site disturbances at points at or between the permit area boundary and the areas approved for land disturbing activities for long -term surface operations or facilities where such areas are within 200 feet of the permit area boundary and where there are no obvious natural or existing demarcations (such as ridges, streams, roads, fences, or similar features) that aid in visually delineating or limiting the disturbance areas. The "proposed land disturbing activities for the mine's long -term surface operations or facilities" do not include temporary or remote, out -lying sites such as methane drainage wells, exploration holes, powerlines, associated roads and other similar disturbances. As such, physical perimeter marker signs or posts will not be utilized at these sites. Physical perimeter marker signs or posts will be maintained until no additional ground - disturbing activities are foreseen which could reasonably lead to disturbances beyond the permit area boundary. This would typically occur when final reclamation surface grading is complete and would be prior to Phase 1 bond release. Soil Stockpiles As West Elk Mine is an underground mine and the majority of the reclamation will not begin until the end of the life of the mine, it is necessary to have subsoil and topsoil stockpiles. The main topsoil pile is located to the south of the run -of -mine coal stack -pad and will be used for reclamation of the main mine facilities area. Some subsoil from the subsoil pile in Sylvester Gulch, (Live Subsoil Pile #1) as well as the topsoil from the stockpile at the North Soil Storage Area (NSSA), will be used for reclamation of the Lower Refuse Pile. MCC has also stockpiled topsoil from the Refuse Pile Expansion (RPE) area and the widening of the mine 2.05 -28 Rev. 06105, 01106, 03106, 04106 & 05106- PRIG; 01109- MR350; 04109- TR116; 04109- MR353; 05109- MR354; 08109- TRIM. 08109- TRI19; 05110 & 08111- MR366